As President of the Virginia Association of Clinical Nurse Specialists, I do not support the remedy before the BON in the petition set forth by Ms Hurley to substitute additional clinical hours for a certification examination.  There is a national endeavor underway, captured in the Consensus Model for Advanced Practice Nursing document, to standardize all aspects of Advanced Practice Nursing.  This effort is clearly needed to address not only the needs of our Commonwealth but the nation’s citizenry in providing access to quality health care and improved patient outcomes.  The Clinical Nurse Specialist is both educated & certified to provide expert nursing care through a rigorous graduate level program and post-program certification examination.  The national effort supports this standard, establishing licensure as an APRN for all APN roles as the first standard to protect the public and certification to validate expertise at this level of nursing practice. Although I sympathize with Ms Hurley’s inability to sit for a CNS certification examination in Women’s Health at this time, there is precedent for her to sit for the Adult Health Clinical Nurse Specialist certification exam.  There are also other possible options to validate her expertise, eg portfolio submission.  The national effort has been underway for several years and other states have grappled with this issue.  Hence, I would ask the BON to not accept additional clinical hours as a substitute for validated Clinical Nurse Specialist expertise.